The Illinois Appellate Court has upheld a protective order against Samantha N. Durbin, limiting her contact with her biological son, D.H., who was adopted by Dominic Henry. The court's decision, filed on November 13, 2026, comes after Henry sought the order due to concerns over Durbin's unauthorized communications with D.H. This ruling is significant as it reinforces the legal protections afforded to children in adoptive situations, especially when there are concerns about their safety.

The case, titled Durbin v. Henry (Docket No. 1-25-1931), centers around the legal rights of Durbin, who lost her parental rights in 2017 due to allegations of abuse. Henry, the adoptive parent, filed for a plenary order of protection against Durbin after she allegedly contacted D.H. without permission. The court's ruling emphasizes the importance of maintaining boundaries in cases involving adopted children and their biological parents.

In June 2025, Henry filed a petition for an order of protection, citing an incident where Durbin and her husband met D.H. in a park without his adoptive parents' knowledge. This led Henry to report D.H. as missing, although he was later found at the park. The petition detailed Durbin's history of abuse, which prompted the court to issue an emergency order of protection shortly after the petition was filed.

Following the emergency order, which was initially set to expire on July 14, 2025, the circuit court extended the order and required Durbin to provide proof regarding D.H.'s desire to communicate with her. Durbin argued that D.H. wanted regular visitation, but the court denied her motion for an in-camera interview with the child, stating that the central issue was whether Durbin had abused D.H.

On August 21, 2025, the circuit court entered a plenary order of protection against Durbin, prohibiting her from contacting D.H. without the express permission of his adoptive parents. The court's findings were recorded, but no transcript or bystander’s report was provided in the appeal, which led to the Appellate Court's ruling.

The Illinois Appellate Court, led by Justice C.A. Walker, affirmed the circuit court's decision, noting that Durbin failed to provide a sufficient record for review. The court stated, "In the absence of such a record, the reviewing court will presume the lower court had a sufficient factual basis for its ruling, and that the ruling was in accordance with the law." This means that without the necessary documentation, the court could not address Durbin's claims regarding due process violations or the appropriateness of the protective order.

Durbin's appeal included several arguments against the ruling, including claims of due process violations and that the order was against the manifest weight of the evidence. However, the court concluded that Durbin did not provide adequate reasoning or evidence to support her claims, stating that her brief lacked specific arguments or references to the record.

The ruling has implications for future cases involving protective orders and parental rights, particularly in situations where a biological parent's rights have been terminated. The court's decision reinforces the importance of providing a complete record in appeals, as the absence of such documentation can hinder a party's ability to challenge a ruling.

Looking ahead, it remains unclear if Durbin will seek further legal recourse. The court's decision is final unless appealed to a higher court, and there are no indications of related cases pending at this time. The ruling serves as a reminder of the complexities surrounding parental rights and the legal protections in place for children in adoptive families.